Contributor and Talent Privacy Notice
We are Second Draft Ltd. We’re a company registered in England and Wales with company number 10647384, whose registered address is at UNIT 34, BUSINESS AND INNOVATION CENTRE, SUNDERLAND SR5 2TA. In this Privacy Notice, we will refer to ourselves as ‘we’, ‘us’ or ‘our’. We are the Data Controller of the personal information we collect, hold and use about you, as explained in this notice.
You can contact us in any of the following ways:
by emailing us at mark@seconddraft.co.uk; or
by writing to us at UNIT 34, BUSINESS AND INNOVATION CENTRE, SUNDERLAND SR5 2TA.
We may update this Privacy Notice from time to time. This version was last updated on November 26th 2024.
Key definitions
The key terms used in this Privacy Notice are defined below, for ease:
Data Controller: the organisation or person responsible for deciding how Personal Information is collected, stored, and used.
Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks on its behalf in relation to the Personal Information. This might be the hosting of a site containing Personal Information, for example, or providing an email marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer base.
Personal Information: any information from which a living individual can be identified. It does not apply to information that has been anonymised.
Special Information: certain very sensitive Personal Information requires extra protection under data protection law. Sensitive data includes information relating to health, racial and ethnic origin, political opinions, religious and similar beliefs, trade union membership, sex life, and sexual orientation. It also includes genetic information and biometric information.
Content: References to “Content” in this Privacy Notice shall mean the development, programme and/or series you have applied for or been approached to appear in and/or any re-edited, re-voiced, reformatted, updated or compilation or any other versions thereof or further series or spin-offs and/or other recorded media (collectively “Content”).
We take the privacy, including the security, of Personal Information we hold about you seriously. This Privacy Notice tells you how we collect Personal Information about you and any other individuals who appear in or are otherwise involved in Content which we produce, and how we use that Personal Information. You should read this Privacy Notice carefully so that you know and can understand why and how we use the Personal Information we collect and hold about you.
Why do we collect Personal Information?
We collect and process Personal Information in connection with our business activities generally and our Content-making activities for a number of reasons including: operating and managing our business effectively and lawfully; contacting individuals about, and assessing individuals’ suitability to appear in, or otherwise be involved in, Content that we produce; as part of and in connection with our Content-making and other activities; producing, exhibiting, exploiting, distributing, publicising, advertising and promoting our Content by any media (now known or hereafter invented) throughout the world; and responding to queries from members of the public.
What Personal Information will we collect
We will, are likely, or may process the following Personal Information (7-9 include Special Information) about you in connection with our business activities and the Content we produce which we may obtain from you directly or from a third party:
your name, your gender, your age and date of birth, your address and contact details such as your email address and telephone number, your handwriting, as well as other basic details about you.
your image, your gender, your age and birth date, information contained within your passport, your driving licence and possibly other official documents which identify you.
information about your past and present personal, home and family life.
information about your past and present professional life including information about your current role and work schedule, your previous work history, your qualifications and your experiences.
whether you consent or object to being identified in Content and if you object, the basis of your objection.
information about you that is on social media and the internet including images of you and other personal information that is contained there.
information concerning your physical and mental health.
information concerning any criminal convictions or cautions you may have, information about any criminal activity you may be or have been involved in and information concerning current criminal proceedings or criminal allegations relating to you or in which you are involved.
your gender identity, ethnicity, disability, politics, trade union membership, genetics, biometrics and sexual orientation.
any and all personal information relating to you, revealed or recorded on cameras and/or microphones and contained within footage and/or sound recordings made for Content, or provided by or sourced from you or a third party in connection with the production and exploitation of Content, including without limitation:
10.1. your image; voice; name; your gender; your age and date of birth; your address and contact details; information about your past and present personal, home and family life; information about your future plans, hopes and aspirations; information about your financial affairs; information about your past, present and future professional life including without limitation information about your current job, your position, work schedule and the nature of your work, your previous work history, your qualifications and your experiences, and your plans, intentions, and hopes for the future in connection with your professional life; and the details of any legal claim made by or against you and enforcement action taken against you or on your behalf, including any assets seized and the circumstances surrounding the seizure.
10.2. information concerning your racial and ethnic origin, political opinions, religious or philosophical beliefs, your membership of a trade union, your health and any medical treatment you receive, your sex life or your sexual orientation; and
10.3. information concerning any criminal convictions or cautions you may have and any other criminal activity you may have been suspected of or involved in; information concerning the nature and status of any arrests, charges, prosecutions, court proceedings or other interactions between you and the authorities.
How do we use your Personal Information and / or Special information?
We process your information for the purposes of our business and Content, including for production, broadcasting, distribution and marketing. As a Data Controller, we are required to have a legal basis for processing your personal data. We will use the information we collect about you for:
a. corresponding with you and/or to contract with you, and for administrative and other purposes in connection with the development, production and exploitation of the Content we produce and/or our other business activities;
b. to administer and manage any application you make to take part in Content we produce;
c. to check your identity, conduct background checks and more generally to assess your suitability to take part in Content we produce;
d. to select contributors to take part in Content we produce;
e. to ensure compliance with our contractual obligations, to you and others, and with all other relevant laws and regulations;
f. for editorial reasons and for the development, production and exploitation of the Content we produce;
g. for diversity monitoring.
What is the lawful basis for processing the above information
The numbers below correspond to the types of Personal Information and / or Special Information set out in the numbered paragraphs above. Alongside this is the lawful basis (and further conditions for processing where relevant) we rely upon in order to process these types of data.
Paragraphs 1, 2, 3, 4, 5 and 6
Processing is necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce.
Paragraphs 1, 2 and 5
Processing is necessary for the performance of our contract with you or in order to take steps prior to entering into the contract.
Paragraph 7
Processing is necessary for the purposes of our legitimate interests and others; and / or necessary for the performance of our contract with you or in order to take steps prior to entering into the contract; and undertaken with your explicit consent.
Paragraph 8
Processing is necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce; and / or necessary for the performance of our contract with you or in order to take steps prior to entering into the contract; and undertaken with your explicit consent and / or undertaken in connection with our artistic/journalistic purposes.
Paragraph 9
Processing is necessary for the purposes of our legitimate interests and others’ e.g. those that publish the Content we produce; and undertaken with your explicit consent.
Paragraph 10.1
Processing is necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce; and / or necessary for the performance of our contract with you or in order to take steps prior to entering into the contract; and / or undertaken in connection with our artistic/journalistic purposes.
Paragraph 10.2 and 10.3
Processing is necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce; and / or necessary for the performance of our contract with you or in order to take steps prior to entering into the contract; and undertaken with your explicit consent; and / or undertaken in connection with our artistic/journalistic purposes.
In addition, following exploitation of Content, such information may be information manifestly made public by you and, if so, we may rely on the relevant provisions of the Data Protection Act 2018 for any further processing of that information.
Consent
Generally, we anticipate that individuals will give their informed consent to take part in and work on Content that we produce. However, we may refer to, or even feature, an individual in Content without their consent, provided we comply with the relevant laws and regulatory codes, such as the Ofcom Broadcasting Code.
Where you have entered into a contract with us to participate in Content, we may be entitled to distribute and show the relevant Content whether or not you later change your mind about participation.
Consenting to take part in Content, and our reliance on your consent to process your personal data are two distinct, different things. We will not generally rely on your consent to process your personal data if you appear in Content. This is something which we normally do as part of our legitimate business interests, for contractual purposes, and/or in connection with our artistic/journalistic purposes.
Sharing your Personal Information
Your Personal Information is processed by our employees and staff. In addition, we use third parties who are contractually engaged to provide services to us which may involve the sharing of your personal information e.g. IT services, legal and accountancy services. We also may need to share your personal information with other organisations from time to time including with:
companies involved with our business activities e.g. co-producers, programme-making partners, third party suppliers, broadcasters, SVOD platforms, post-production houses, sales agents, distributors;
broadcasting regulators e.g. Ofcom;
the police or other regulatory bodies as required by law in connection with the investigation of crimes.
Although we are based in the UK, our business is global and so we may need to transfer your personal information outside the UK.
Wherever your information is transferred to organisations outside the UK, we will ensure that adequate regulations or appropriate safeguards, such as standard data protection clauses recognised or issued in accordance with the UK data protection regime, are in place to ensure the safety and security of your personal information and that it is processed in accordance with this Privacy Notice (unless an exemption applies). You can find out more about these safeguards by contacting us using the contact details at the top of this Privacy Notice.
Keeping your personal information secure
We have put in place appropriate security measures to prevent your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How long with you keep my information for?
We will keep the information we obtain about you when you provide contributions to us for no longer than is necessary for the purposes for which it is processed. In general, we will keep your information until the Content has been produced, delivered and for a period afterwards. In considering how long to keep it, we will take into account its relevance to our business and your contribution either as a record or in the event of a legal claim.
Some information, such as production footage of your contribution will be held for up to (and in rare cases beyond) 10 years as we have an ongoing legitimate interest in retaining this.
Personal information that is no longer required will be deleted/destroyed
How can you access the Personal information and/or Special Information we hold about you?
You have the right to obtain a copy of the data we hold about you in line with the Data Protection Laws. If you would like to obtain a copy of your data, please contact us using the details set out at the start of this Privacy Notice.
If you would like to:
i) change, update, correct and/or access your data, or in certain circumstances, request that your data be erased, restricted and/or withdraw your consent for us to process your data;
ii) notify us that you no longer wish to be considered as a potential contributor (provided you’ve not already taken part in the Programme);
iii) amend, update, restrict, remove your data for Marketing Communications, for casting of other programmes and/or other purposes previously agreed by you; and/or
iv) submit any queries concerning this Privacy Notice and/or how we process your data;
Please email us at hello@seconddraft.co.uk with details of your request.
If you’d like to raise a complaint about how we process your Personal information and/or Special Information, please contact us as set out above in the first instance and we will endeavour to resolve the matter. In the event that you are not satisfied with how we have responded and/or handled your complaint, you may refer the matter to the data protection regulator (the Information Commissioner’s Office).